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The Bribery Act 2010


December 31, 2011

Ministry of Justice

Hospitality/Christmas Gifts in Business: Social politeness or bribery?

The Christmas season is upon us and it’s customary within most organisations and businesses to “tip” or “thank” suppliers, subcontractors and clients with various gifts or hospitality. But are you aware of your need to mitigate the risk of bribery?

Did you know…

The Bribery Act 2010 came into force on 1st July 2010 with a clear definition of “giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so.”

Some businesses like to get to know their clients better by taking them to hospitality events such as football matches, horse racing etc., and some just like to treat them with gifts at Christmas. None of these are deemed unacceptable by the Ministry of Justice as long as companies follow the “Six Principles” to mitigate any bribery risks:

  1. Proportionality – The action you take should be proportionate to the risks you face and to the size of your business.
  2. Top Level Commitment – Those at the top of an organisation are in the best position to ensure their organisation conducts business without bribery.
  3. Risk Assessment – Think about the bribery risks you might face.
  4. Due Diligence – Knowing exactly who you are dealing with can help to protect your organisation from taking on people who might be less than trustworthy.
  5. Communication – Communicating your policies and procedures to staff and to others who will perform services for you enhances awareness and helps to deter bribery by making clear the basis on which your organisation does business.
  6. Monitoring and Review – The risks you face and the effectiveness of your procedures may change over time.

Bearing all the above in mind, companies shouldn’t stop making an effort with clients and suppliers, they’re what make our business’s turn over and keeps us afloat, procedures are there to be followed and as long as “gifts” are monitored, nobody is saying they should stop.

ExecutiveVPA can help you remain compliant to The Bribery Act 2010, contact us now for more information.

For more information and guidance on The Bribery Act 2010 visit the Ministry of Justice’s website.

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